HyperRail voor Android - Privacy Policy

Welcome, and thank you for your interest in HyperRail (HyperRail, “we,” or “us”), our web site at  www.hyperrail.be (the “Site”), and all related web sites, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals though from written or oral means, such as email or phone (collectively, together with the Site, our “Service”).

This Privacy Policy (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by purchasing or using the Service, you accept the privacy practices described in this Policy.

Definitions

“User” means a user of HyperRail.

“User Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.

“Personal Data” means any information relating to an identified or identifiable natural person.

2. The Information We Collect on the Service:

We do not collect personal data, unless the user actively provides this data by e-mailing feedback. We collect anonymous information from or through the Service. The legal bases for processing of personal data are primarily that the processing is necessary for providing customer support to the user, and that the processing is carried out in HyperRail's legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy.

2.1 User-provided Information. When you submit feedback by sending an e-mail, we may collect Personal Data. Examples of Personal Data include name and email address, and your feedback. There is no other way to send us personal data.

2.2 “Automatically Collected" Information. When a User uses the Service, we may automatically record certain information from the User’s device by using various types of technology. This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. This information is gathered from all Users. You can read below why this data is collected.

2.3 Information from Other Sources. We don't obtain information from third parties and sources other than the Service. We don't combine or associate information from other sources with Personal Data that we collect through the Service, because we don't collect personal data and don't use other sources for data.

3. How We Use the Information We Collect

We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:

3.1 Operations

We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable User.

3.2 Improvements

We use anonymous information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require HyperRail to process User Data, then the data will only be used in anonymized or aggregated form.

3.3 Communications

We may use a User’s email address or other information only to contact that User for administrative purposes such as customer service after the user made the first contact by e-mailing us.

3.4 Cookies and Tracking Technologies

We do not collect information or track you through cookies or similar technologies. We only monitor aggregate site and application usage metrics such as total number of visitors and pages viewed without the use of any third party service; Even though we don't use them, you can obtain more information about cookies by visiting  http://www.allaboutcookies.org.

3.5 Analytics

We use Google Analytics to measure and evaluate access to and traffic on the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users' and Visitors’ activity on our Site. For more information, see  Google Analytics Privacy and Data Sharing.

We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Users.

We use Google Play Services, Firebase Crash reporting, Performance, Analytics to measure and evaluate access to and traffic in the application, and to provide the application functionality to our users. Firebase, Google Play, and Crashlytics operate independently from us and has its own privacy policy, which we strongly suggest you review. See

We take measures to protect the technical information collected by our use of Firebase or Crashlytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Users.

Link to privacy policy of third party service providers used by the app

4. To Whom We Disclose Information

Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable User. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

4.1 Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) to assist such parties in understanding our Users’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service. For example, we might write a blog post on what the most popular usage of routeplanning applications is (for example if users rather search for departures, or if they rather search for journeys).

4.2 Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

4.3 Change of Ownership

Information about Users and Visitors, including Personal Data, will not be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Client Data will not be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service.

5. Your Choices

5.1 Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, you may contact us by mailing us at [email protected]. At your request, we will have any reference to you deleted or blocked in our database.

You may update, correct, or delete your information and preferences at any time by mailing us. Please note that while any changes you make will be reflected instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may decline to share certain Personal Data with us, in which case we may not be able to provide you customer feedback. We need some way to reply to you.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact HyperRail's Data Protection Officer at [email protected]. You also have a right to lodge a complaint with data protection authorities.

This provision does not apply to Personal Data that is part of Client Data. In this case, the management of the Client Data is subject to the Client’s own Privacy Policy, and any request for access, correction or deletion should be made to the Client responsible for the uploading and storage of such data into the Service.

5.2 Navigation Information

You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the  Google Analytics Opt-out feature.

5.3 Opting out from Commercial Communications

We don't send commercial communications. You are always opted out.

6. Third-Party Services

The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

9. Interest Based Advertising

We don't do advertising. We don't share any data with advertising partners because we don't have and don't want any such partners.

10. Do Not Track Policy

We don't track you. When you visit our site with DNT enabled, it is up to Google Analytics to obey this signal. You can read about this in their privacy policy mentioned above.

11. Third Party Cookies

California law requires that operators of websites and online services disclose whether other third parties may collect personally identifiable information about an individual's online activities from their site or service. We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Site. These third parties include (1) business partners, which collect information when you view or interact with one of their advertisements on the Site; and (2) advertising networks, which collect information about your interests when you view or interact with one of their advertisements.

The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Site and on other sites across the Internet tailored to your apparent interests.

The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.

11.1 The Following Types of Cookies Are Or May Be Used in the Site:
11.2 The Following Cookies are Used in the Site:

None

12. Minors and Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at  [email protected] and request that we delete that child’s Personal Data from our systems.

The Service is not intended to be used by minors, and is not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the Service, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as indicated in the “How to Contact Us” section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.

13. Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

14. Data Retention

We only retain the Personal Data collected for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.

15. Data Transfer

We may transfer, process and store Personal Data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Data to the U.S., we will protect it as described in this Privacy Policy.

User's personal data (your email when you contact us) is stored in Amsterdam, The Netherlands.

17. Data Controller and Data Processor

HyperRail does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. HyperRail is largely unaware of what Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.

Because HyperRail does not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, HyperRail is not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”)  and does not have the associated responsibilities under the GDPR. HyperRail should be considered only as a processor on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, HyperRail does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of HyperRail in connection with HyperRail’s provision of Services to Clients. Such actions are performed or authorized only by the applicable Client or User.

The Client or the User is the data controller under the Regulation for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.

HyperRail is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is HyperRail responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.

18. Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

19. How to Contact Us

Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at  [email protected]. If you have any concerns or complaints about this Policy or your Personal Data, you may contact HyperRail’s Data Protection Officer by email at [email protected].

Last update: May 22, 2018